Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
ITAT held that no specific charge was framed against the assessee in the show-cause notice issued u/s 274 read with Section 270A for misreporting of income. While the assessment order did not specify the exact charge, the show-cause notice initiated penalty proceedings for both under-reporting and misreporting of income. However, in the penalty order, the Assessing Officer concluded it was a case of under-reporting due to misreporting of income and levied penalty u/s 270A(9)(a). ITAT decided in favour of the assessee on the ground that no clear charge was framed in the show-cause notice.
ITAT held that no specific charge was framed against the assessee in the show-cause notice issued u/s 274 read with Section 270A for misreporting of income. While the assessment order did not specify the exact charge, the show-cause notice initiated penalty proceedings for both under-reporting and misreporting of income. However, in the penalty order, the Assessing Officer concluded it was a case of under-reporting due to misreporting of income and levied penalty u/s 270A(9)(a). ITAT decided in favour of the assessee on the ground that no clear charge was framed in the show-cause notice.
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TaxTMI 
TaxTMI 
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